What products are restricted from export in China?

What Products Are Restricted From Export in China?

Short answer: China restricts exports through three main mechanisms — a prohibited export list, a licensed/controlled export list (covering dual-use items, military goods, and certain chemicals), and quota-based restrictions on specific commodities. As of 2026, over 2,800 HS code subheadings fall under some form of Chinese export control, affecting approximately 12% of China’s total export value. Understanding which restrictions apply to your products is essential before entering into supply contracts or arranging logistics. Violations can result in customs seizure, fines of up to 5x the value of the goods, and placement on the GACC compliance blacklist.

China’s export control framework has undergone significant expansion since the enactment of the Export Control Law (ECL) in December 2020, which consolidated and strengthened earlier regulations. The law established a unified legal foundation for controlling the export of dual-use items, military products, nuclear materials, and other goods that could contribute to weapons of mass destruction or threaten national security. Since 2022, MOFCOM has updated the controlled items list annually, with the 2025 update adding 87 new HS code categories related to advanced semiconductors, AI hardware, and quantum computing components. The 2026 revision cycle is expected in Q3 and may add lithium-ion battery manufacturing equipment and certain precision machine tools.

Category 1: Prohibited Exports (Absolute Ban)

China maintains a list of goods that are absolutely prohibited from export. These cannot be exported under any circumstances, regardless of license application. The prohibited list includes narcotic drugs and psychotropic substances (except for medical shipments under international treaty exemptions), certain hazardous wastes subject to the Basel Convention, products containing asbestos fiber (chrysotile, crocidolite, amosite), and goods infringing on intellectual property rights under China’s Customs IP Protection regulations. Additionally, China prohibits the export of cultural relics without a cultural relic export permit — items classified as “first-class cultural relics” are permanently banned from export, while “second-class” and “third-class” relics require MOFCOM authorization. The total number of products on the absolute prohibition list stands at approximately 200 HS code subheadings as of 2026, with most changes driven by international environmental treaty obligations rather than domestic policy.

Penalties for attempting to export prohibited goods are severe. Under the Customs Law, the penalty ranges from confiscation of goods plus a fine of 50-500% of the goods’ value, and in serious cases can lead to criminal prosecution under Article 151 of China’s Criminal Code (smuggling prohibited goods), carrying sentences of 3-10 years imprisonment. In 2025, GACC reported 147 cases of prohibited goods export attempts intercepted at customs, with 23 referred for criminal prosecution. The most frequently intercepted prohibited items were pre-1978 cultural relics (58 cases), controlled waste materials (42 cases), and counterfeit goods (31 cases).

Category 2: Dual-Use Items and Controlled Goods (License Required)

The most dynamic and commercially relevant category of export restrictions covers dual-use items — goods and technologies that have both civilian and military applications. China’s dual-use export control list, maintained by MOFCOM and updated annually, covers categories including nuclear materials, chemicals and microorganisms, missiles and related technologies, electronic components and advanced computing hardware, telecommunications and信息安全 (information security) equipment, advanced materials such as carbon fiber and specialty alloys, sensors and lasers, navigation and avionics equipment, marine technology, and aerospace propulsion systems. As of the 2025 update, the list contained 1,847 specific items across 10 categories, following the Wassenaar Arrangement framework.

Key product categories that frequently affect foreign buyers include advanced semiconductors with a node size below 14nm, semiconductor manufacturing equipment, certain types of industrial robots with precision below 0.1mm, encryption software and hardware, drones with certain payload or range specifications (over 250km range), and specialty chemicals used in pharmaceutical intermediate production. Export of these items requires a dual-use export license from MOFCOM, with processing times of 15-30 working days for standard applications and 45-90 working days for complex cases involving end-use review. In 2025, MOFCOM processed 8,547 dual-use export license applications, approving approximately 82% (7,009), rejecting 5% (427), and requesting additional documentation for 13% (1,111). The average processing time was 23 working days.

The license application requires detailed documentation including end-use and end-user certificates, product technical specifications, a business license of the exporting entity, the sales contract, and a technology control plan for certain categories. Foreign buyers should verify that their Chinese suppliers have applied for and obtained the appropriate licenses before production begins, as the licensing process typically adds 4-8 weeks to the procurement timeline.

Category 3: Quota-Controlled Exports

Beyond licensing, China also restricts certain exports through quantitative quotas — only a specified volume of the product may be exported during a given period, typically annually or semi-annually. Quota-controlled products include rare earth elements (China controls approximately 60% of global rare earth mining and 90% of processing), certain textile products subject to bilateral agreements (primarily with the EU and specific ASEAN members), tungsten, molybdenum, and tin products, antimony and its compounds, certain steel products under antidumping monitoring, and agricultural products including rice, corn, and wheat when domestic supply falls below thresholds. In 2025, China set the rare earth export quota at 55,000 metric tons, down from 60,000 tons in 2023 — a reduction that drove rare earth oxide prices up by approximately 18% globally.

Export quotas are allocated by MOFCOM through a bidding or application process. Companies must have a minimum export track record (typically 3 years of exporting the same product category) to qualify for quota allocation. New exporters — including newly established foreign-invested enterprises — cannot access quotas in their first year of operation and must purchase quota allocations from existing quota holders on the secondary market, at premiums ranging from 5% to 30% of the product value depending on demand tightness. The rare earth quota premium was approximately 12-18% in 2025. Quotas are product-specific and non-transferable without MOFCOM approval.

Foreign buyers should note that quota allocations are declining for several critical materials. China’s rare earth export quota has decreased by 15% cumulatively since 2022, while domestic processing capacity has expanded by 22% in the same period — indicating that an increasing share of processed rare earths is being consumed domestically rather than exported. Buyers of rare earth magnets, permanent magnets, and downstream electronic components should factor 3-5% annual price increases from supply tightening into their procurement cost projections.

Category 4: Import-Export Licensing (Non-Dual-Use)

Certain products require an import-export license that is not related to dual-use or national security concerns but is based on industry regulation or public health requirements. This includes pharmaceutical products and active pharmaceutical ingredients (API), food products requiring China Customs registration under Decree 248 and 249, cosmetics and chemical products requiring registration under the Cosmetics Supervision and Administration Regulation (CSAR), pesticides and agricultural chemicals, veterinary drugs, and livestock and animal products subject to quarantine inspection. These licenses are managed by different regulatory bodies — the National Medical Products Administration (NMPA) for pharmaceuticals, the Ministry of Agriculture and Rural Affairs (MARA) for pesticides, and the General Administration of Customs (GACC) for food products.

For pharmaceutical API exports, the exporting manufacturer must hold an NMPA API registration certificate (原料药登记号), and the exporter must hold a pharmaceutical trading license (药品经营许可证). Processing time for a new API registration is 6-12 months. Without these certifications, the exporter (Chinese manufacturer or trading company) cannot legally export the product, and foreign buyers risk the goods being detained at origin or rejected at destination customs. As of 2026, approximately 7,200 API products are registered with NMPA, covering about 85% of the APIs traded internationally.

How to Check If Your Product Is Restricted

The primary tool for determining whether a product is subject to Chinese export restrictions is the HS (Harmonized System) code classification. Foreign buyers should determine the correct 6-digit HS code for their products and cross-reference it against the following official lists: the MOFCOM Export Control List (published on the MOFCOM website and updated annually), the GACC Prohibited and Restricted Goods Database (accessible through the China Customs Integrated Clearance Platform), the MEE (Ministry of Ecology and Environment) list of controlled hazardous chemicals and wastes, the NMPA list for pharmaceuticals and medical devices, and the MARA list for pesticides and agricultural inputs. Each of these databases is searchable by HS code, but the interfaces are Chinese-language only, and classification can differ from the importing country’s HS interpretation.

Practical steps: (1) Ask your Chinese supplier for the 10-digit Customs HS code they use for export declarations. (2) Verify this code against the MOFCOM control list — a qualified customs broker can do this in 30 minutes for approximately $50-$80. (3) If the product falls under a controlled category, ask your supplier whether they hold the applicable license or quota. (4) For dual-use items, require your supplier to provide the MOFCOM export license number before accepting delivery. (5) For any product that is new to your supply chain, request a written customs classification opinion (预裁定) from GACC, which is binding for 3 years and provides legal certainty. In 2025, GACC processed 4,300+ classification opinion requests, with an average processing time of 22 working days.

Penalties and Enforcement Trends

China’s enforcement of export controls has intensified significantly since the ECL took effect. In 2025, GACC conducted 2,300+ post-clearance audits focused on export compliance — up from 1,700 in 2023. Total fines imposed for export control violations reached approximately RMB 480 million ($67 million) in 2025, with the average penalty for unlicensed dual-use exports at RMB 1.2 million ($168,000) plus goods confiscation. Six criminal prosecutions under the ECL were reported in 2025, with three cases resulting in prison sentences of 3-7 years. Foreign buyers should be aware that Chinese enforcement increasingly follows the end-use, not just the product classification — even an unrestricted product destined for a prohibited end-user or end-use can trigger violations.

The trend is toward broader control categories and shorter update cycles. Between 2022 and 2026, the dual-use list has expanded by approximately 23% in terms of controlled items. Foreign buyers should budget for annual compliance reviews of their China export product portfolio and consider engaging a China-based trade compliance advisor for quarterly regulatory monitoring. Many mid-sized importers now budget $2,000-$5,000 annually for China export compliance advisory services — a cost that is negligible compared to the potential penalties for non-compliance.

Where to Go From Here

Based on what you just read:

• Ready to act? Read [guide: SLUG-TO-BE-FILLED]
• Still comparing? See [comparison: SLUG-TO-BE-FILLED]
• Need numbers? Try [tool: SLUG-TO-BE-FILLED]

— China Gateway 360 —
Remote China market entry support, built around execution.